Justia Wyoming Supreme Court Opinion Summaries

Dixon Dean Cole was originally charged in 1996 with multiple counts of sexual assault and immoral or indecent acts with minors. Through a plea agreement, he pled guilty to one count of sexual assault in the fourth degree (a misdemeanor) and one count of immoral or indecent acts with a minor (a felony). He received suspended sentences and probation, and after fulfilling all court-ordered requirements, he was discharged from probation in 2001. Both convictions required him to register as a sex offender due to the ages of the victims.Years later, Cole was charged with failing to register as a sex offender. While those charges were pending, he sought expungement of both convictions and requested to be relieved of his registration duty. The District Court of Sweetwater County expunged his misdemeanor conviction (applying the felony expungement statute in error) and terminated his duty to register for the felony conviction. The State objected, arguing Cole was statutorily ineligible for expungement due to his registration status.On appeal, the Supreme Court of Wyoming determined that although the district court used the incorrect statute for the misdemeanor expungement, Cole was otherwise eligible under the proper statute, and the results would have been the same. The Court declined to consider arguments about whether Cole posed a danger to society, as these were not properly raised in the district court. Regarding the termination of the sex offender registration requirement, the Supreme Court found no abuse of discretion, noting Cole met all statutory prerequisites and that a pending failure-to-register charge did not automatically bar relief.The Supreme Court of Wyoming affirmed both the expungement of the misdemeanor conviction and the order terminating Cole’s duty to register as a sex offender. View "State v. Cole" on Justia Law

Lloyd Haack passed away in March 2024, leaving behind a purported will that named his son, Howard Haack, as the sole beneficiary and personal representative. Shawn Renee Logan, claiming to be Mr. Haack’s financial advisor, petitioned for probate and expressed belief in another will, but no such document was found. The court admitted the existing will to probate and appointed Howard Haack and Bailey Baxter as co-personal representatives. Logan contested Howard’s appointment, alleging forgery, but her petition was dismissed for lack of standing. Kristy Martinez, Haack’s granddaughter, was determined to have standing to contest both the will and the appointment. She then filed a petition contesting the will’s validity within the probate case, requested a jury trial, and the co-personal representatives responded with affirmative defenses and a motion to dismiss, arguing the will contest required a new civil action separate from the probate matter.The District Court of Fremont County held a hearing to address these procedural questions. The co-personal representatives relied on prior Wyoming Supreme Court decisions, including Matter of Estate of Meeker and Matter of Estate of Rowe, arguing that statutory requirements and civil procedure rules necessitated a separate civil action for will contests. Martinez, however, argued that Wyoming law permits such contests to proceed within the probate matter itself and cited Gaunt v. Kansas University Endowment Association and Russell v. Sullivan for support.The Supreme Court of Wyoming reviewed the certified questions from the district court. Employing statutory interpretation and examining relevant precedent, the Court held that Wyoming statutes do not require a will contest to be filed as a completely separate civil action with a new case number and heading. Instead, a will contest under Wyo. Stat. § 2-6-301 et seq. can proceed as a separate proceeding within the existing probate matter. Accordingly, the Court answered the certified question in the negative and declined to address the second question regarding jurisdictional defects. View "In the Matter of the Estate of Haack" on Justia Law

The case concerns an altercation in Sheridan, Wyoming, during which Cody McCalla and his friend encountered Patrick Mudd and Mudd's girlfriend over a parking dispute. After a verbal confrontation, McCalla and his friend moved their vehicle and proceeded toward the fairgrounds. Mudd stood on the sidewalk, and a second confrontation ensued between McCalla and Mudd, escalating into physical violence. After several exchanges, McCalla ultimately punched Mudd, causing him to fall, hit his head, and later die from his injuries. McCalla was charged with involuntary manslaughter.The District Court of Sheridan County reviewed several pretrial motions. McCalla moved to compel production of unredacted law enforcement reports, which the district court denied, finding the redacted portions exempt from disclosure under Wyoming Rule of Criminal Procedure 16. McCalla also moved to dismiss the charge, claiming immunity from prosecution under Wyoming Statute § 6-2-602(f) on grounds of self-defense. The district court held an evidentiary hearing, requiring McCalla to proceed first, as his motion alone did not establish a prima facie case. After testimony, the district court found McCalla met his prima facie burden, but the State proved by a preponderance of evidence that McCalla was the initial aggressor in the second altercation and did not use reasonable defensive force, denying immunity.The Supreme Court of Wyoming reviewed the appeal. It held the district court did not err in requiring McCalla to proceed first at the evidentiary hearing, found no error in the district court’s determination that McCalla was the initial aggressor and thus not entitled to self-defense immunity under Wyoming Statute § 6-2-602(f), and declined to address the discovery issue, as it was not properly preserved for appeal. The Supreme Court affirmed the district court’s rulings. View "Mccalla v. The State of Wyoming" on Justia Law

A Wyoming firearms manufacturer sought to expand its operations by constructing a new facility. The company, unable to directly access specific state economic development funds, partnered with a city and a local non-profit to obtain funding, resulting in a written agreement outlining each party’s roles. The non-profit was charged with managing the project, including hiring architects and contractors. During and after construction, the manufacturer identified substantial design and construction defects, including climate control problems, leaks, and structural issues. The manufacturer sued the non-profit for breach of contract and also sued the architect and contractor, asserting it was a third-party beneficiary of their contracts with the non-profit.In the District Court of Park County, the court dismissed the manufacturer’s claims against the architect and contractor, finding it was not an intended third-party beneficiary under their contracts, and granted summary judgment to the non-profit on all but one claim, determining that the non-profit’s contractual obligations were limited to financial administration of the project. The remaining claim was later dismissed by stipulation.The Supreme Court of Wyoming reviewed the case de novo. The court held that the district court erred in dismissing the manufacturer’s claims against the architect and contractor because, accepting the complaint’s factual allegations as true and considering the relevant contracts, the manufacturer had sufficiently alleged facts that could support third-party beneficiary status and breach of contract. The court also found the district court erred in granting summary judgment to the non-profit, concluding that the contract’s language and context imposed broader duties on the non-profit, including project administration and construction oversight, not merely financial management. The Supreme Court of Wyoming reversed the lower court’s orders of dismissal and summary judgment, allowing the manufacturer’s claims to proceed. View "Gunwerks, LLC v. Forward Cody Wyoming, Inc." on Justia Law

In this case, a business owner discovered that his yard’s fence had been cut, a lock removed, and a distinctive skid steer tractor missing. Months later, a law enforcement officer familiar with the stolen tractor observed a similar machine at the defendant’s scrapyard. Upon inspection, the tractor showed signs of tampering, including a removed serial number plate, a recently spray-painted exterior, and a matching hidden serial number. The defendant initially claimed the tractor had been inherited from his late uncle and had always been black, but he later argued at trial that it was purchased from another individual named Franco, and that he had confused two similar tractors.The defendant was charged with felony theft in the District Court of Uinta County. At trial, he sought to introduce a document purporting to be a bill of sale for the tractor through a witness, Kyle Hartley, who testified to seeing the transaction occur. However, Hartley’s description of the document did not match the document offered—specifically, he recalled both parties signing, but the document lacked the defendant’s signature. The district court ruled that foundation for the document had not been established and excluded it unless further authentication was provided. As a result, the defendant testified solely to lay the foundation, and the document was admitted. The jury convicted the defendant, and he was sentenced to prison.On appeal to the Supreme Court of Wyoming, the defendant argued that the district court abused its discretion in requiring additional foundation for the bill of sale, effectively forcing him to testify. The Supreme Court held that the district court did not abuse its discretion, as the witness’s testimony did not sufficiently authenticate the document due to discrepancies. The conviction and judgment were affirmed. View "Titmus v. The State of Wyoming" on Justia Law

Gunwerks sought to expand its business by constructing a new manufacturing facility in Cody, Wyoming, a project involving public funds and coordinated through Forward Cody Wyoming, Inc. Forward Cody retained Plan One Architects and Sletten Construction of Wyoming, Inc. as the project's designer and general contractor, respectively. Sletten hired various subcontractors, including Big Horn Glass, Inc. (BHG), to perform specific tasks. After completion, Gunwerks alleged numerous construction defects in the facility, including issues with concrete, finishes, HVAC, siding, drainage, ceiling heights, door and window flashings, and the shooting tunnel. Gunwerks sued Forward Cody, Plan One, and Sletten for breach of contract and breach of the covenant of good faith and fair dealing.Sletten responded to Gunwerks’s lawsuit by filing a third-party complaint against its subcontractors, including BHG. Sletten claimed that, should it be found liable to Gunwerks, subcontractors responsible for any deficient work should indemnify it for those damages. Sletten did not specifically admit or allege deficiencies in BHG’s work but sought to preserve its right to recovery if any subcontractor was found at fault. Approximately ten months after Sletten’s third-party complaint, BHG moved for summary judgment in the District Court of Park County, arguing that Sletten had not presented evidence showing BHG caused any of the alleged damages. The district court granted summary judgment for BHG, finding that Sletten had not countered BHG’s prima facie showing with disputed facts, relying instead on speculation.On appeal, the Supreme Court of Wyoming reviewed the district court’s summary judgment ruling de novo, applying the same standard as the lower court and viewing the record most favorably to Sletten. The Supreme Court affirmed the district court’s decision, holding that Sletten failed to present admissible, competent evidence creating a genuine issue of material fact regarding BHG’s liability for any alleged defects. The court found Sletten’s evidence speculative and conclusory, insufficient to defeat summary judgment. The disposition was affirmed. View "Sletten Construction of Wyoming, Inc. v. Big Horn Glass, Inc." on Justia Law

A mother with a history of involvement with the Department of Family Services had her youngest child, BAR, removed from her care after police found her intoxicated, in possession of methamphetamine, and responsible for leaving children unattended in a running vehicle. She was subsequently arrested and convicted of child endangerment. The Department developed a reunification case plan focused on sobriety, mental health, stable housing, and parenting skills. Despite receiving significant support and services from the Department, the mother repeatedly failed to comply with her case plan. She did not maintain sobriety, attend counseling consistently, or secure stable housing, and her visitation with BAR was sporadic. Her progress was further hampered by recurring involvement in unstable and sometimes violent relationships and continued substance abuse.The District Court of Natrona County first placed BAR in the Department’s custody following an abuse and neglect petition. The juvenile court initially pursued a reunification plan but later shifted to a plan of adoption due to the mother’s lack of progress. After a five-day bench trial, the district court found clear and convincing evidence that BAR had been in foster care for at least fifteen of the most recent twenty-two months and that the mother was unfit to have custody and control of BAR, citing ongoing instability, untreated mental health issues, substance abuse, and lack of consistent visitation. The court terminated the mother's parental rights under Wyoming Statute § 14-2-309(a)(v).On appeal, the Supreme Court of the State of Wyoming reviewed whether sufficient evidence supported termination under the statute. The court affirmed the district court’s decision, holding that clear and convincing evidence established the statutory grounds for termination based on the mother’s unfitness and the duration of BAR’s time in foster care. View "B.A.R. v. State Ex Rel. Department of Family Services" on Justia Law

Police investigating a sexual assault executed a search warrant at a mobile home occupied by three individuals, including the appellant. During the search of one resident’s bedroom, officers found a glass pipe believed to contain methamphetamine residue. The appellant and his mother, who also lived in the home, denied the presence of drugs when questioned. Based on the discovery, law enforcement obtained a second warrant to search the entire residence for controlled substances. This second search led to the discovery of methamphetamine and drug paraphernalia in a bench located in the appellant’s bedroom, resulting in his arrest and charge for felony possession.The District Court of Campbell County presided over the criminal case. The appellant filed a motion to suppress the evidence, arguing that the officer’s affidavit for the second search warrant omitted material facts, such as the pipe being found in a locked bedroom accessible only to one resident, and that these omissions undermined probable cause. After a hearing, the district court denied the motion, finding that the omitted facts would not have defeated probable cause, as the resident in whose room the pipe was found could access the entirety of the home, including the appellant’s bedroom. The appellant then entered a conditional guilty plea, reserving the right to appeal the suppression ruling.Reviewing the appeal, the Supreme Court of Wyoming affirmed the district court’s decision. It held that even if the omitted facts had been included in the affidavit, probable cause existed to search the entire mobile home because the resident implicated by the initial pipe discovery had access throughout the home. The Court concluded that the district court did not err in denying the motion to suppress, and the conviction was affirmed. View "Urrutia v. State" on Justia Law

The case concerns a defendant who was charged with felony interference with a peace officer and, after pleading guilty, was placed on supervised probation with a suspended prison sentence. Over the next few years, the defendant’s probation was twice revoked and reinstated, with the court imposing varying conditions in response to admitted violations, including substance use and other misconduct. After the defendant was given additional chances, including substance abuse treatment and a split sentence, the State eventually filed a third petition to revoke probation, alleging further violations such as drug use, failure to attend probation meetings, and inadequate progress in treatment.Following the third petition, the District Court of Goshen County held an adjudicatory hearing to determine whether the defendant violated probation terms. Both parties presented evidence and argument on the alleged violations. After the hearing, the district court found that the violations were proven by a preponderance of the evidence and that the defendant’s actions were willful. The court then immediately revoked probation and imposed the previously suspended prison sentence, without conducting a separate dispositional phase or allowing the defendant to present mitigation.The Supreme Court of Wyoming reviewed the case under the plain error standard because the defendant did not object during the proceedings. The court held that, although Wyoming law does not require separate hearings for adjudication and disposition in probation revocation matters, both phases must be conducted with appropriate opportunity for mitigation and consideration of willfulness. The district court erred by failing to conduct the dispositional phase, denying the defendant procedural rights and undermining the fairness of the proceedings. The Supreme Court reversed the district court’s order and remanded for a proper disposition hearing in accordance with Wyoming law. View "Velasquez v. The State of Wyoming" on Justia Law

In 1979, the appellant and his brother took a truck in Laramie, Wyoming, and drove it to Casper. The appellant pled guilty to felony Unauthorized Use of Automobile. The district court sentenced him, suspended the sentence, and placed him on probation. It further ordered that upon successful completion of one year of probation, he could withdraw his guilty plea and have the matter dismissed. After completing probation, the appellant was discharged, his guilty plea was withdrawn, and the case was dismissed. Despite this, the Wyoming Division of Criminal Investigation maintained records incorrectly indicating he was a convicted felon.In 2025, the appellant petitioned the District Court of Albany County to expunge his records under Wyo. Stat. Ann. § 7-13-1502, which provides for expungement of felony convictions. The State did not oppose the petition. The district court denied the request, reasoning that the appellant’s case was resolved through a deferred prosecution process—specifically, the withdrawal of the guilty plea and dismissal after probation—under statutes governing deferred dispositions. It concluded that, as there was no felony conviction, there was no conviction to expunge. The appellant’s motion to reconsider was also denied, and he appealed.The Supreme Court of Wyoming reviewed the case and applied a de novo standard to statutory interpretation. It held that Wyo. Stat. Ann. § 7-13-1502 unambiguously limits expungement eligibility to persons convicted of felonies. The court determined that a deferred prosecution resulting in annulment or withdrawal of a guilty plea and dismissal does not constitute a conviction. Therefore, the appellant is not eligible for expungement under this statute. The Supreme Court of Wyoming affirmed the district court’s denial of the expungement petition. View "Lynch v. The State of Wyoming" on Justia Law